Pursuant to rule 65, plaintiff hereby moves for the issuance
of a temporary restraining order to restrain and enjoin the defendants
from preventing or interfering with plaintiffs' communication
to any representives of public media organs, or members of the
general public.

In support of this Application plaintiffs submit a Certification,
pursuant to Local Rule 205 (a), and Declarations by Concepcion
Picciotto and Joseph Vigorito concerning the specific facts which
gave rise to this Application for a Temporary Restraining Order.

U.S. Park Police Officer Berkowitz, whose actions prompted
this application, appears frequently in the papers previously
filed in this case. See, e.g., Amended Complaint, paras. 23,
24, 25 and 26. Declaration of Concepcion Picciotto in Support
of the Amended Complaint, para. 20. Declaration of William Thomas
in Support of the Amended Complaint, paras. 29, 41, 43.

WHEREFORE, plaintiffs pray this court will temporarily restrain:

(1) the defendants, their agents, and all persons acting
under their direction and authority from disrupting or interfering
with plaintiffs' communication to the general public and/or members
of the communications media;

(2) the Park Police from assigning Officer Berkowitz to
duty in Lafayette Park.

I William Thomas, hereby state that, on this 10th day
of September, 1989 I caused a copy of the foregoing Plaintiffs'
Application for a Temporary Restraining Order to be hand-delivered
to the Office of U.S. Attorney at Judiciary Square, 555 4th Street
N.W., Washington, D.C.